A Kyiv-based IT company relocated twelve employees to Warsaw in spring 2022. Three years later, those same employees face a shifting legal framework – extended deadlines, new documentation requirements, and uncertainty about what comes next. The company's HR team is asking the right questions. Most Polish employers, however, are asking them too late.
Temporary protection for Ukrainian nationals in Poland is governed by the Act on Assistance to Ukrainian Citizens in Connection with Armed Conflict on the Territory of Ukraine (the Ukraine Assistance Act), which implements the EU Temporary Protection Directive. The current protection period runs through 4 March 2026, with Poland having introduced domestic measures to extend residence and work entitlements beyond that date. Ukrainian nationals holding temporary protection status are entitled to work in Poland without a separate work permit, access the public healthcare system, and enrol children in Polish schools.
This guide sets out the step-by-step procedure for maintaining and documenting temporary protection status, explains the key deadlines and costs, identifies the three most common employer mistakes, and maps three business scenarios across manufacturing, IT, and foreign investment contexts. Each section opens with a direct answer, so readers can locate the information they need without reading the entire article.
What is temporary protection and who qualifies under Polish law?
Temporary protection is a collective, fast-track status that bypasses the standard asylum procedure. Under Polish law, it applies to Ukrainian nationals who entered Poland on or after 24 February 2022 and to certain third-country nationals who held valid residence in Ukraine before that date. The Urząd do Spraw Cudzoziemców (Office for Foreigners, UdSC) is the central authority responsible for registration. The Zakład Ubezpieczeń Społecznych (Social Insurance Institution, ZUS) manages social contributions, and the Powiatowy Urząd Pracy (District Labour Office, PUP) oversees employer notifications.
Eligibility turns on three conditions: Ukrainian citizenship (or qualifying third-country status), entry into Poland on or after 24 February 2022, and registration in the national PESEL system with the "UKR" flag. The PESEL number is the anchor document. Without it, neither employment nor access to public services is properly documented. Employers who skip the PESEL verification step expose themselves to liability under the Act on Employment of Foreigners.
Third-country nationals who lived in Ukraine before the conflict may qualify, but the conditions are narrower. They must have held a valid Ukrainian residence permit on 24 February 2022 and be unable to return safely to their country of origin. In practice, this group includes Belarusian, Russian, and other CIS nationals – a category that requires individual legal assessment before any employment decision is made.
One misconception worth addressing directly: temporary protection is not a visa. It does not appear in a passport as a stamp in the traditional sense. The operative document is the confirmation of PESEL registration combined, where issued, with a zaświadczenie (certificate) from the local commune (gmina). Employers should request both documents and retain copies in the personnel file.
What are the current deadlines and how has the protection period been extended?
The original EU Temporary Protection Directive set an initial 12-month period, extendable up to three years. Poland aligned with the EU Council decision extending protection through 4 March 2026. Domestically, the Ukraine Assistance Act introduced a parallel mechanism: where EU-level protection expires or is not renewed, Polish law provides a bridging residence entitlement of up to 18 months beyond the last valid protection date. This means that, in the most favourable reading, Ukrainian nationals could retain lawful residence in Poland until September 2027 – though this depends on further legislative action.
For employers, the practical deadline is not the EU expiry date but the employee's individual PESEL registration status. If the PESEL "UKR" flag lapses or is revoked, the work entitlement lapses with it. Employers must verify PESEL status at the point of hiring and again at each annual HR audit. A lapse discovered during a Państwowa Inspekcja Pracy (State Labour Inspectorate, PIP) audit can result in fines of up to PLN 30,000 per illegal worker.
Two additional deadlines matter for employees planning to regularise their status. Applications for a temporary residence permit (zezwolenie na pobyt czasowy) must be filed before the temporary protection period ends. Filing in time triggers a legal fiction of continued lawful residence until the permit is decided – even if the decision takes 12 months or more. Missing the filing window forfeits this protection and leaves the individual in an irregular status that cannot be easily corrected.
- EU protection period: through 4 March 2026
- Domestic bridging entitlement: up to 18 months beyond EU expiry
- Temporary residence permit application: must be filed before protection expires
- PIP fine for employing without valid status: up to PLN 30,000 per worker
- PESEL "UKR" flag: verify at hiring and at each annual HR review
We secured a regularisation of status for a manufacturing client's workforce of over 40 Ukrainian employees in the Mazowieckie region (autumn 2025), after an internal audit identified PESEL flag discrepancies that would have triggered PIP liability within 60 days.
How does the work entitlement operate in practice?
Ukrainian nationals with valid temporary protection status are entitled to work in Poland without a separate work permit. This is the single most important practical advantage of temporary protection over standard immigration routes. Under ordinary rules, an employer hiring a non-EU national must obtain a zezwolenie na pracę (work permit) – a process that typically takes 30 to 90 days and costs PLN 100 to PLN 200 in administrative fees. Temporary protection bypasses this entirely.
The employer's obligation is notification, not authorisation. Within seven days of commencing employment, the employer must notify the relevant District Labour Office through the praca.gov.pl portal. This notification is not a permit application – it is a compliance record. Failure to notify does not void the employment contract, but it does expose the employer to a fine of up to PLN 5,000 and creates a gap in the official record that complicates any future status regularisation for the employee.
For roles requiring professional qualifications – medicine, law, engineering – additional sector-specific rules apply. A Ukrainian doctor working in a Polish hospital needs recognition of their medical diploma by the relevant professional chamber, regardless of temporary protection status. Employers in regulated sectors should not assume that the work entitlement is unconditional. It removes the immigration barrier; it does not remove the professional qualification barrier.
The EU Blue Card (Niebieska Karta UE) is a separate instrument available to highly qualified third-country nationals, including Ukrainians. It requires a minimum gross salary threshold – currently set at 150% of the average gross salary in Poland, approximately PLN 11,000 per month – and a university degree. For Ukrainian professionals who plan to remain in Poland long-term, the EU Blue Card offers a more stable residence base than temporary protection. The two instruments can be held concurrently during a transition period. For detailed guidance on relocating employees from other EU member states, see our article on global mobility and relocating employees to Poland from the Czech Republic.
To discuss how the work entitlement framework applies to your workforce, email info@kordeckipartners.com.
What are the three most common employer mistakes?
Most compliance failures with Ukrainian temporary protection are procedural rather than deliberate. They arise from misunderstanding which document controls the work entitlement, missing the notification deadline, or conflating temporary protection with standard third-country employment rules. Each mistake carries a different risk profile.
Mistake one: relying on the passport alone. A valid Ukrainian passport confirms identity. It does not confirm temporary protection status. The operative documents are the PESEL confirmation and, where applicable, the commune certificate. Employers who file the District Labour Office notification without verifying PESEL status are creating a false compliance record. If the PESEL "UKR" flag was never activated or has lapsed, the employee is not legally entitled to work – and the employer bears the liability.
Mistake two: missing the seven-day notification window. The notification must reach the District Labour Office within seven calendar days of the employment start date. Many employers treat this as a seven-business-day window. It is not. A notification filed on day eight is a late notification. Repeated late notifications are a pattern that PIP auditors note and flag for follow-up inspection.
Mistake three: failing to plan for status transition. Temporary protection is, by definition, temporary. Employers who have built operational dependencies on Ukrainian staff – and many Warsaw and Kraków tech companies have – need a transition plan. That plan involves identifying which employees qualify for a temporary residence permit, which qualify for the EU Blue Card, and which may face gaps in their right to work. Starting this assessment six months before the protection period ends is not early. It is the minimum lead time for an orderly transition.
Our team obtained a successful outcome in a PIP audit challenge for an IT client in Małopolska (spring 2026), after the inspectorate questioned the timing of seven District Labour Office notifications filed over a 14-month period.
Three business scenarios: manufacturing, IT, and foreign investor
The temporary protection framework operates differently depending on the employer's sector, workforce size, and long-term plans. Three scenarios illustrate the range of issues that arise in practice.
Manufacturing (Silesia, 80 Ukrainian workers). A Silesian manufacturer employing 80 Ukrainian nationals faces a workforce planning problem as the 2026 deadline approaches. Most workers hold temporary protection status and have not applied for a temporary residence permit. The employer's risk is operational: if 20 workers lose their right to work simultaneously, production lines stop. The correct approach is a phased regularisation programme – filing temporary residence permit applications in batches over six months, prioritising workers in skilled roles. Cost per application: PLN 440 in state fees plus legal fees. Timeline: 6 to 12 months per application under current processing times at the Voivode's office.
IT sector (Warsaw, 15 Ukrainian developers). A Warsaw IT company employing 15 Ukrainian developers has a different problem. Its employees are highly qualified and well-paid. Most qualify for the EU Blue Card. The transition from temporary protection to EU Blue Card involves a residence permit application, a salary verification, and a diploma recognition process. The employer should cover the administrative costs (PLN 440 per application) and provide HR support for document collection. The EU Blue Card, once granted, is valid for three years and is transferable within the EU – a significant benefit for developers considering mobility. For context on how Polish corporate structures interact with workforce planning, see our analysis of share deal vs asset deal structures in Polish M&A.
Foreign investor (Wielkopolska, greenfield project). A German investor establishing a manufacturing facility in Wielkopolska plans to hire 30 Ukrainian engineers. The project timeline is 18 months. Temporary protection will cover the initial hiring phase, but the investor needs a long-term workforce plan. The recommended structure is: hire under temporary protection now, initiate EU Blue Card applications for senior engineers within three months, and file temporary residence permit applications for the remaining workforce six months before protection expires. Compliance with posted worker rules – including A1 certificates where applicable – is a parallel obligation. Our article on posted workers from Cyprus to Poland and A1 certificates addresses the cross-border dimension of this structure.
Each scenario requires a different sequencing of applications, a different budget, and a different risk allocation between employer and employee. There is no single template.
Specific workforce planning for Ukrainian nationals requires early action. Delays in filing applications preclude the legal fiction of continued lawful residence – an irreversible consequence that disrupts operations and creates personal liability risk for HR directors who certified compliance. To receive an expert assessment of your workforce's current status, contact info@kordeckipartners.com.
Frequently asked questions
Q: Can a Ukrainian national with temporary protection status work for any employer in Poland without restrictions?
A: Yes, with two qualifications. The work entitlement under temporary protection is not tied to a specific employer, sector, or region – unlike a standard work permit, which is employer-specific. However, regulated professions (medicine, law, architecture) require separate recognition of qualifications regardless of immigration status. Employers in regulated sectors must verify both the immigration entitlement and the professional qualification before commencing employment.
Q: How long does a temporary residence permit application take, and what does it cost?
A: Under current processing times at the Voivode's office, applications take between 6 and 12 months. The state fee is PLN 440. Filing in time – before the temporary protection period expires – triggers a legal fiction of continued lawful residence for the duration of the proceedings. This means the employee may legally continue working even if the decision takes 12 months. Missing the filing deadline forfeits this protection entirely.
Q: Does the whistleblower protection framework in Poland apply to Ukrainian employees who report employer non-compliance?
A: Yes. The Polish Act on the Protection of Whistleblowers applies to all individuals in an employment relationship, regardless of nationality or immigration status. A Ukrainian employee who reports an employer's failure to comply with immigration notification requirements is protected from retaliation. Employers should ensure that their internal whistleblower channels are accessible in Ukrainian and that HR teams understand the non-retaliation obligation.
What to prepare: compliance checklist
Before an employment lawyer Warsaw-based or otherwise reviews your documentation, the following items should be in order for each Ukrainian employee:
- PESEL number with confirmed "UKR" flag – verified against the official register
- District Labour Office notification filed within seven calendar days of employment start
- Copy of PESEL confirmation and commune certificate retained in personnel file
- Temporary residence permit application filed (or scheduled) before protection expiry
- EU Blue Card eligibility assessment completed for employees earning above PLN 11,000 gross monthly
KORDECKI & Partners is a law firm based in Warsaw and Krakow, advising business clients across 30 jurisdictions. Our team combines expertise in Polish and international law with a practical approach to employment, global mobility, and Ukrainian Desk matters. We work with Polish entrepreneurs, foreign investors, and in-house legal teams navigating the full range of temporary protection, work permit Poland procedures, and EU Blue Card applications. To discuss your situation, contact info@kordeckipartners.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. KORDECKI & Partners assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@kordeckipartners.com.